AML Policies & Procedures Manual.
AML Policies & Procedures Manual.
AML-CFT Law Article 16.1(a) and AML-CFT Decision Article 4.1(a)-(b), DNFBPs are obliged to document their ML/TF business risk assessment, including methodology, analysis and supporting data, and to make them available to the Supervisory Authorities upon request.
DNFBPs should incorporate into their documentation, the information used to conduct the ML/TF business risk assessment in order to demonstrate the effectiveness of their risk assessment processes.
Examples of such information include, but are not limited to:
- Organisation’s overall risk policies (for example, risk appetite statement, customer acceptance policy, and others, where applicable).
- ML/FT risk assessment model, methodology and procedures, including such information as organisational roles and responsibilities; process flows, timing and frequency; internal reporting requirements; and review, testing, and updating requirements.
- Risk factors identified, and input received from relevant internal sources, including the designated AML/CFT compliance officer.
- Details of the inherent and residual risk-factor analysis that constitutes the risk assessment
The documentation measures taken by DNFBPs should be reasonable and commensurate with the nature and size of their businesses.
Please contact us for further information on aml@aml360.io